The United States Supreme Court today unanimously reaffirmed
that the mere implementation of an abstract idea in a computer is
not sufficient to render it eligible for a patent.
The Court's decision in Alice Corp. v. CLS Bank
concerned patents directed to a scheme for mitigating settlement
risk in financial transactions. In contrast with the patent at
issue in the 2010 Bilski v. Kappos case, the Alice patents
included method, system and computer-readable medium claims, each
of which recited elements of a computer.
In reaching its decision, the Court drew in part on its 2012
decision in Mayo Collaborative Services v. Prometheus
Laboratories, Inc., which had set out a framework for
determining whether claims are directed to patent-eligible subject
matter. Under that framework, a court must first determine whether
the patent claims are directed to a patent-ineligible concept, such
as an abstract idea or a law of nature. If so, then the claim's
elements must be
